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Press Release

United States Files Complaint to Forfeit Nearly $1 Million From Companies Accused of Enabling North Korean Sanctions Evasion

For Immediate Release
U.S. Attorney's Office, District of Columbia
Two Companies Allegedly Violated Sanctions by Acting as Intermediaries for ZTE's Export of US-origin Goods to North Korea

            WASHINGTON - The United States has filed a complaint to forfeit $955,880.85 associated with two companies, announced Michael R. Sherwin, Acting U.S. Attorney for the District of Columbia; Emmerson Buie, Jr., Special Agent in Charge of the FBI Chicago Field Office; and Steven Cagen, Special Agent in Charge of the HSI Denver Field Office.

            The complaint alleges the Ryer International Trading Limited and Rensy International Trading Co., Limited acted as intermediaries for North Korea’s purchase and acquisition of telecommunications equipment from ZTE, which included US-origin components.

            ZTE exported millions of U.S.-origin parts to North Korea between 2010 and 2016, receiving payments in U.S. dollars through China-based shell companies, Ryer and Rensy. Ryer and Rensy were intermediaries to negotiate purchase contracts, request payments, and receive the U.S.-origin goods on behalf of ZTE’s North Korean customers.

            Ryer’s proprietors attempted to invest the proceeds of their activity in the EB-5 immigrant investor program, which provides eligibility for permanent residence in the United States.

            “This complaint illuminates how procurement networks coordinate with front companies to move North Korean money through the United States to obtain U.S.-origin technology in violation of sanctions and money laundering laws,” said Acting U.S. Attorney Sherwin. “This case demonstrates that we will use all tools in our Threat Finance Unit’s portfolio to disrupt activity by the North Korean regime that harms U.S. national security, regardless of where they are doing business.”

            "The evasion of U.S. financial sanctions by foreign actors will not be tolerated, and the FBI will continue to work with federal law enforcement partners to ensure that there are consequences for those seeking to profit through illegal money laundering activities,” said Emmerson Buie, Jr., Special Agent in Charge of the FBI’s Chicago Field Office.

            “This seizure demonstrates how seriously we take our commitment to safeguarding the interests of the United States against criminal elements aiding North Korea,” said Steven Cagen, special-agent-in-charge, HSI Denver. “This case underscores the resolve of Homeland Security Investigations to use its investigative authority to disrupt this threat.”

            The complaint was filed on September 11, 2020, in the U.S. District Court for the District of Columbia. According to the complaint, Ryer and Rensy also acted as a conduit for North Korean money laundering through sanctioned North Korean financial institutions. 

            The United Nations Panel of Experts reported as to how North Korean banks have been able to evade sanctions and continue to access the international banking system. Specifically, despite strengthened financial sanctions, North Korean networks are accessing formal banking channels by maintaining correspondent bank accounts and representative offices abroad that are staffed by foreign nationals making use of front companies. These broad interwoven networks allow North Korean banks to conduct illicit procurement and banking activity.

            The claims made in the complaint are only allegations and do not constitute a determination of liability.

            The FBI’s Chicago Field Office and HSI’s Colorado Springs Office are investigating the case. Assistant U.S Attorneys Zia M. Faruqui, Michael Grady, and Brian P. Hudak, and National Security Division Deputy Chief Liz Cannon are litigating the case, with assistance from Paralegal Specialist Brian Rickers, Legal Assistant Jessica McCormick, and Records Examiner Angela De Falco.

Updated September 11, 2020

Financial Fraud
National Security
Press Release Number: 20-106